Emergency
Action Plan
Emergency
Response Plan
Emergency

“A workplace emergency is an unforeseen
situation that threatens your employees,
customers, or the public; disrupts or shuts
down your operations; or causes physical
or environmental damage”
– “How to Plan for Workplace Emergencies &
Evacuations,” U.S Dep’t of Labor,
Occupational Safety & Health Administration,
Publication OSHA 3088/Revised 2001
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Examples
Floods
Hurricanes
 Tornadoes
 Fires
 Blizzards
Toxic gas releases
Chemical spills
 Radiological
accidents/RDD
 Explosions
 Civil disturbances
 Workplace violence
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Why Pre-plan for
Emergencies?
Legal Requirements
 SARA
Title III/EPCRA (40 CFR 355)
(40 CFR 265.50)
 HAZWOPER (1910.120)
 Hazcom (1910.1200)
 OSHA EAP (1910.38)
 Fire Extinguishers (1910.157)
 Fixed Extinguishing Systems (1910.160)
 RCRA
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Legal Requirements
 Fire
Detection Systems (1910.164)
 Alarm Systems (1910.165)
 Fire Protection (Subpart L, Appendix A)
 Local/state requirements
Business Reasons
 More
coordinated, timely response
effects of adverse exposure to
employees
 Minimize liability
 Bottom line is $$$
 Minimize
Industry Advantages
 You
know (or should know!) exactly what
you have
 You know where chemicals are stored &
used
 You know your processes & plant layout
 You know your products & wastes
 You know how wastes are disposed of
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Fire departments have
no such advantages;
they can really only plan
for generalities
Components Of Pre-planning
 In
many cases you don’t necessarily need
separate plans for different regulatory
requirements
 Consolidate where possible!
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Different Names Depending
On Regulation Or Standard
 Emergency
Action/Evacuation Plan
 Emergency Response Plan
 Contingency Plan
 Site Safety Plan
 Training Plan
 Incident Action Plan
 This Plan, That Plan, Everybody Wants a
Plan Plan
Each Type Of Action Different,
But Similar Req’ts
 Nature
of site emergencies
of emergencies
 Procedures for dealing with emergencies
 Types
EAP Components
 Procedures
for reporting fire or other
emergency
 Procedures for emergency evacuation,
including type of evacuation & exit route
assignments
 Procedures to be followed by employees
who remain to operate critical plant
operations before they evacuate
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EAP Components
 Procedures
to account for all employees
after evacuation
 Procedures to be followed by employees
performing rescue or medical duties
 Name or job title of every employee who
may be contacted by employees who need
more information about plan or explanation
of duties under plan
EAP Components
 Outs/exemptions:
– Very few (fire brigade & extinguishers)
– Can be orally-communicated (≤10 employees)
 Still
 OSHA
have burden-of-proof of plan’s viability
E-tool
– www.osha.gov/SLTC/etools/evacuation/index.
html
ERP Components
 Defined
“Emergency” earlier
response
 Emergency
– Response effort by employees from outside
immediate release area or by other designated
responders (i.e., mutual aid groups, local fire
departments, etc.) to occurrence which
results, or likely to result, in uncontrolled
release of a hazardous substance
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Emergency Response Plan
 Pre-emergency
planning & coordination
 Personnel roles, lines of authority, training
& communication
 Emergency recognition & prevention
 Safe distances & places of refuge
 Site security & control
 Evacuation routes & procedures
Emergency Response Plan
 Decontamination
 Emergency
medical treatment & first aid
 Emergency alerting & response
procedures
 Critique of response & follow-up
 PPE & emergency equipment
What is Called For?
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What is Called For?
Contingency Plan
 Roles
of response personnel
 Incident Command System (Incident
Management System)
 Training
 Communications & alert notification
systems
 Site mapping
 Site security & control
 Places of safe refuge
Contingency Plan (cont’d)
 Evacuation
routes
 Decontamination
 Medical
program
response procedures
 Documentation
 Reporting procedures
 Emergency
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The “One-Plan”
The “One-Plan”
 Also
known as Integrated Contingency
Plan (ICP)
 Allows facility to comply with multiple
federal planning requirements by
consolidating into one functional
emergency response plan
One-Plan Signatories
 EPA
 OSHA
 Coast
Guard
 DOI/Minerals
Management Service
 DOT/RSPA
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ICP Elements
 EPA
RCRA
– 40 CFR 264, Subpart D
– 40 CFR 265, Subpart D
– 40 CFR 79.52
 EPA
Oil Pollution Prevention
– 40 CFR 112
 Coast
Guard FRP
– 33 CFR 154
ICP Elements
 DOT
RSPA/FRP
– 49 CFR 194
 OSHA
EAP
– 29 CFR 1910.38(a)
 OSHA
PSM
– 29 CFR 1910.119
ICP Elements
 OSHA
HAZWOPER
– 29 CFR 1910.120
 EPA
CAA RMP
– 40 CFR 68
 MMS
Facility Response Plan
– 30 CFR part 254
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How to Get It
 www.epa.gov/region1/enforcement/epcra/o
neplan.html
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